Interpretation of a lifting device and its ability to act as a rescue retrieval system as it applies to OSHA's permit required confined space entry standard.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 6, 1995

Mr. Joseph M. Bouchard
Coordinator of Safety Services
Fairfield University
Fairfield, Connecticut 06430-7524

Dear Mr. Bouchard:

This is in response to your letter dated October 4, 1994, requesting an interpretation of a lifting device and its ability to act as a rescue retrieval system as it applies to OSHA's permit required confined space entry standard (29 CFR 1910.146). Please accept our apology for the delay in this response.

Interpretation of the provision of the Permit Required Confined Spaces Standard

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 6, 1995

Mr. James J. Goumas
Vice President, Safety & Regulatory Compliance
Rust Industrial Services, Inc.
3003 Butterfield Road
Oak Brook, Illinois 60521

Dear Mr. Goumas:

This is in response to your letter dated May 25, 1995 requesting an interpretation of the provision of the Permit Required Confined Spaces Standard (29 CFR Part 1910.146(e)(6)) which requires employers to retain cancelled entry permits for at least one year.

What OSHA safety standards are applicable to underground sewer pipeline inspection camera systems.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 11, 1995

Mr. Alan K. Sefton
President
Pearpoint, Inc.
72055 Corporate Way
Thousand Palms, California 92276

Dear Mr. Sefton:

Relationship between training requirements for those who will perform permit space rescue services in accordance with PRCS and the Hazardous Waste and Emergency Response standard.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 6, 1995

Joanne B. Linhard
Organization Resources Counselors, Inc.
1910 Sunderland Place, N.W.
Washington, D.C. 20036

Dear Ms. Linhard:

Guidance in determining whether elevator pits meet the definition of confined spaces.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 27, 1995

Mr. Edward A. Donoghue Associates Inc.
[Donoghue Associates Inc.]
Code and Safety Consultant to NEII
Shushan Road, P.O. Box 201
Salem, NY 12865-0201

Dear Mr. Donoghue:

Determining whether certain spaces meet the definition of a "confined space" according to the Permit-Required Confined Spaces standard.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 27, 1995

Mr. William Taylor
ELB & Associates
605 Eastowne Dr.
Chapel Hill, N.C. 27514

Dear Mr. Taylor:

This is in further response to your letter of March 24, 1994, requesting guidance in determining whether certain spaces meet the definition of a "confined space" according to the Permit-Required Confined Spaces (PRCS) standard. Please accept our apology for the delay in this response.

Applying Permit-Required Confined Spaces (PRCS) standard to a workplace that is a multi-family residential commercial building

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 27, 1995

Mr. James Sharpe
Consolidated Engineers Services
2345 Crystal Drive
Suite 1000
Arlington, Virginia 22202

Dear Mr. Sharpe:

This is in response to your letter requesting guidance in applying the 1910.146 - Permit-Required Confined Spaces (PRCS) standard to your workplace that is a multi-family residential and commercial building. Please accept our apology for the delay in this response.

For the purposes of clarity, we have restated your questions separately and answered them individually.

Question

Determining whether certain spaces routinely would be considered confined spaces by applying the (PRCS) standard's definition.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 23, 1995

Mr. Mark Arriens CleanHarbors Environmental Services Companies 1200 Crown Colony Drive P.O. Box 9137 Quincy, MA 02269

Dear Mr. Arriens:

This is in further response to your letter requesting guidance in determining whether certain spaces with which your company has to address routinely would be considered confined spaces by applying the Permit-Required Confined Spaces (PRCS) standard's definition. Please accept our apology for the delay in this response.

OSHA's Permit-required Confined Spaces Standard.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

April 24, 1996

Mr. Verne R. Brown
c/o ENMET Corporation
P.O. Box 979
Ann Arbor, MI 48106-0979

Dear Mr. Brown:

Permit-required confined spaces and control of hazardous energy; vehicle LOTO.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.